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Commercial Restroom Products & ADA Compliance
Commercial Restroom Products & ADA Compliance
Presenters
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Danny Gleiberman
Manager – Product Compliance and
Governmental Affairs
Sloan Valve Company
Los Angeles, CA
Celeste Johnson
Global Regulatory Manager
Sloan Valve Company
Franklin Park, IL
Mary Phelps
Strategic Account Manager
Sloan Valve Company
Crosby, TX
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Agenda
This webinar covers:
• Americans with Disabilities Act (ADA) overview
• History
• Scope
• Enforcement
• Impact of ADA in the commercial restroom
• Design
• Product implications
• Updated Access Board guidance
• Review by product type
• Where to get more information
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What is ADA?
The Americans with Disabilities Act (ADA):
• Prohibits discrimination
• Guarantees that people with disabilities have the same opportunities
as everyone else
• Modeled after the Civil Rights Act of 1964 prohibiting discrimination
on the basis of race, color, religion, sex, or national origin
• Is an "equal opportunity" law for people with disabilities
To be protected by the ADA one must:
• Have a disability, which is defined by the ADA as a physical or
mental impairment that substantially limits one or more major life
activities
• Be a person who has a history or record of such an impairment
• Be a person who is perceived by others as having such an
impairment
The ADA does not specifically name all of the
impairments that are covered. July 26, 1990
Who Makes & Enforces ADA Rules?
History
1968 – Architectural Barriers Act (ABA) makes federal facilities accessible to people with
disabilities
1973 – The United States Access Board created as an independent federal agency to
develop and enforce accessibility standards
1982 – The Access Board publishes the first comprehensive “Minimum Guidelines for
Accessible Design”
1990 – The ADA expands the responsibilities of the Access Board beyond federal facilities
to include airports, bus and rail stations, and many other public and private facilities – not
just those funded by the government. Electronics, information technology, and medical
diagnostic equipment added later
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The United States Access Board and the US Department of Justice
ADA ApplicabilityStandards
2010 - The Americans with Disabilities Act was revised to adopt regulation for
enforceable accessibility standards called the 2010 ADA Standards for Accessible
Design
The 2010 Standard was required for:
• New construction
• Alterations
• Program accessibility
• Barrier removal
Applicability
• Title II - All services, programs, and activities provided or made available by public
entities
• Title III - Public accommodation, commercial facility, or private entity that offers
examinations or courses related to applications, licensing, certification, or
credentialing for secondary or postsecondary education, professional, or trade
purposes
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Businesses that provide goods or services to the public are called “public accommodations”
ADA Enforcement & PenaltiesIdentification of Non-compliance
• AHJ (Authority Having Jurisdiction)
• Inspectors
• Citizen or Employee Complaint alleging disability discrimination
Enforcement
• US Department of Justice civil lawsuit
• Private lawsuits
• Mediation
Penalties
• $75,000 for 1st violation
• $150,000 for subsequent violations
• Lawsuits
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ADA Obligations to Comply & Common MisconceptionsWho is obligated to comply?
• Manufacturer is responsible for product design
• Contractor / Installer is responsible for installation
• Architect / Engineer is responsible for spatial design
• Building Owner is responsible for maintenance
Common ADA misconceptions
• “ADA lawsuits are flooding the courts”
• “No disabled persons will use this space”
• “It’s close enough”
• “I can fix it after someone complains”
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USDOJ vs CT Dept. of
Transportation
Train Station required to
make toilet rooms
accessible
USDOJ vs CT Hotel
Adjustment of paper
towel, soap and feminine
products dispensers in
lobby restrooms to ADA
height
USDOJ vs CT Hotel
18 months to completely
renovate lobby toilets
USDOJ vs CT Hotel
30 days to submit plans
for compliant public
restroom doors, grab
bars, toilet height, stall
space, door pulls, urinal
height, lavatory heights
and clearances, towel
dispensers, and signs
ADA Enforcement Examples
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Our Objective
To provide you with Sloan product-related information that will help you be ADA-compliant.
Dr. Anthony Fauci, Director, National Institute of Allergy and Infectious Diseases washes
his hands in the White House using a Sloan EBF85 Automatic Sensor Faucet
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Toilets & Grab Bars
Water Closet Grab BarsExcerpts from 2010 ADA Standards for Accessible Design
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“Rear Wall Grab Bar at Water Closets”
“Spacing of Grab Bars –Projecting Objects”
“Spacing of Grab Bars –Recessed Objects”
“Water Closet Grab Bars – Cross Section
and Clearance”
Guidance is incomplete – requires clarification
Water Closet Grab BarsUpdated US Access Board Guidance for Flushometer Toilets
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“Rear Wall Grab Bar” “Side Wall Grab Bar” “Minimum Clearance” “..so that reach and use of grab bars is
not impeded”
Some Considerations before We Get Started…
• Grab bar heights are measured
to the top of the gripping surface
• When ranges in heights are
provided, attention should be
given to the optimal product for
compliance
• Enforcement is not always
consistent but we strive to
provide solutions
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Exposed Flushometer Solutions
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Concealed Flushometer and Sensor Solutions
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CX Valve – A Complete Solution
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Side View Front View
Access Board Guidance Q&A March 2020
Q. How can conflicts between the rear grab bar and the required location of flush
controls be resolved?A. If plumbing codes require a flush control location that conflicts with the rear grab bar, the grab bar may
be split or shifted to the open side. This is permitted only where applicable codes mandate flush controls
in such a location.
Q. Are automatic (motion sensor) flush controls required to be on the open side of the
water closet?A. No. Motion activated flush controls are not required to be on the open side of the water closet. If a
water closet has a manual flush control in addition to a motion activated one, it is recommended, but not
required, that the manual control be located on the open side of the water closet. Manual flush controls,
even those intended for custodian use, are helpful at water closets and urinals when the motion sensor
fails to activate.
Q. Are flush controls located on valves, walls, or tanks that are centered on the fixture
compliant (i.e., on the open side)?A. Manual flush controls, including push buttons, must be usable from a point between the centerline and
the open side of the fixture. A portion of the control can be outside the range if it is usable without having
to reach beyond the water closet centerline from the open side.
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Children’s Toilets & Grab Bars
Children’s Toilet RequirementCurrent ADA Guideline
• This table has never been implemented
• There are no products available to meet these specific heights
• Split and offset grab bars are the only options
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Many architects dislike split
grab bars
Split and Offset Grab Bars
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Split Offset
Where an administrative authority requires flush controls for flush valves to be located in a
position that conflicts with the location of the rear grab bar, that grab bar shall be permitted to
be split or shifted to the open side of the toilet area. - US Access Board
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Urinals
ADA Urinals
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Max. 17” from floor; any rim height less than 17” is in full compliance. Must project at least 13.5” from wall.
Older stall-type urinals installed in floor comply
Overlap
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Lavatories & Sinks
ADA Lavatories & Sinks
• Wheelchair clear floor space directly in front of fixture at least 30” wide and 48” long
• Clear floor space underneath lavatory no less than 17” and no greater than 25”
• Lavatory or counter surface not more than 34” above finished floor
• Fixture must include knee/toe clearances
• Insulated or covered exposed pipes to prevent injury
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Exposed Pipes & Surfaces
• Water supply and drain pipes under lavatories and
sinks should be insulated or otherwise configured
to protect against contact
• There should be no sharp or abrasive surfaces
under lavatories and sinks
• If angle brackets are used for mounting, the design
must include a cover or element of insulation
around the P trap and water stops
• Most designers will meet this requirement by
including an enclosure (stainless steel or cabinet
style)
ADA Restroom Lavatory & Accessory Height & Reach
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Height of Lavatories and Sinks
Wheelchair-accessible lavatories must be less than 7” thick
Lavatory or counter surface mounted max 34” above finished floor
Allows for 27” knee clearance
Obstructed High Forward Reach
Mounting heights for restroom accessories
should be not more than 44” to 48”
depending on counter depth
• Faucets
• Paper towel dispensers
• Soap dispensers
• Hand dryers
• Mirrors
• Waste receptacles
Obstructed Side Reach
For wall or counter-mounted fixtures,
how far away user is from fixture
determines how high fixture can be
located
ADA Floor Space
• Wheelchair clear floor space directly in front of
fixture at least 30” wide and 48” long
• The clear floor space needed by the sink can
go all the way to the wall as long as there is no
obstruction. This is especially critical for larger
sinks
• There needs to be at least one station that has
30 inches of clear space from left to right
• Many plumbing codes require 30 inches
between every station of the sink
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30” min
30” min
48
” m
in
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Deck-mounted Faucets, Soap Dispensers, & Hand Dryers
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ADA Faucets, Soap Dispensers & Hand Dryers
• User activates without tight grasping, pinching or twisting
of the wrist, and with no more than 5 lbs of pressure
• Operating components of faucet no higher than 48” from
ground
• Sensor-activated faucets improve user accessibility and
comply with ADA
On-deck accessibility
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Wall-mounted Hand Dryers
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Wall-mounted Hand Dryer Design ConsiderationsSuggested mounting heights for ideal performance (from floor to bottom of dryer):
• Men: 45” (114 cm)
• Women: 43” (109 cm)
• Teenagers: 41” (104 cm)
• Children: 35” (89 cm)
• ADA: Mounting heights for restroom accessories should be not more than 44” to 48” depending on counter depth
Note: When mounting for any user, ensure that it is mounted below the 48” ADA maximum
Quantity recommendations:
• One dryer for every two sink stations is sufficient for most applications
• For high-traffic applications, one dryer per sink station is suggested
Optional add-ons for hand dryers:
• Recess kit for ADA compliance
• Noise reduction nozzle to reduce the decibel level by 9dB (but increases dry time by approximately 3 seconds)
• Wall guards to protect walls from splashes
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Mirrors
Access Board Guidance Q&A
Q. Can accessible mirrors be located above lavatories?
A. Accessible mirrors can be located above lavatories or countertops if the
bottom of the reflecting surface is 40” max. above the finish floor (§603.3).
The bottom of the reflecting surface of mirrors not located above lavatories
or countertops must be 35” max. above the finish floor.
Q. If a toilet room has a full-length mirror and a mirror above a
countertop or lavatory, must both types comply?
A. No. The Standards require only one mirror in a toilet room to comply. If
mirrors are provided above lavatories or counters and at other locations in
a toilet room, it is advisable, but not required, that one of each type comply.
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Showers
ADA Showers
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Drawings courtesy of barrierfree.org
Zero Threshold Shower Pans
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Side Elevation Threshold (ADA section 608.7)
Image courtesy of Sloan, Stone & Steel Group
For More Resources
ADA Standards For Accessible Design
ADA Checklist for Existing Facilities
The United States Access Board Homepage
The United States Access Board Guidance for Toilet Rooms
Sloan CEU Courses
Sink Selection for Sustainability and Accessibility
Specifying Plumbing Fixtures for K-12 and Higher Education Facilities
Selecting Plumbing Fixtures for Commercial Restrooms in Healthcare Facilities
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Find your local Sloan representative for more
information
Sloan Rep Locator tool
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Edwards, Platt & Deely, West Babylon, NY
• Local code knowledge
• Familiarity with existing sites
• Product knowledge
• Available for onsite consultation
Sloan Mobile Showroom
Sloan Customer Care Center
Phone: 800.982.5839
Hours: 7:00 AM - 5:00 PM (CST) Monday – Friday
Sloan Technical Support
P: 888.756.2614
F: 800.737.3061
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Questions?
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July 2nd
Flushometer Care and
Maintenance Part 1 –
Manual Diaphragm Units
Upcoming Sloan Training Webinars
July 9th
Power Supply Options
and Installation
Recommendations for
Sloan Sensor Faucets
July 16th
Sustainability and Sloan
Commercial Restroom
Products
Training Comments, Questions, or Suggestions?
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Andrew Warnes
Manager – Technical Training
Sloan Valve Company
10500 Seymour Avenue
Franklin Park, IL USA 60131-1259
Office: +1-800-982-5839
E-mail: [email protected]
Web: sloan.com
